The Administration strongly opposes H.R. 1883, the "Iran Nonproliferation
Act of 1999." The Administration shares with the Congress a strong
interest in promoting nonproliferation, and in combating Iran's efforts to
acquire weapons of mass destruction (WMD) and their missile delivery
systems. U.S. leadership is critical to the required international effort
to attack this problem. H.R. 1883 would weaken the U.S. ability to
persuade the international community to halt such transfers to Iran.
Because the bill would undermine U.S. nonproliferation goals and
objectives, the President's senior advisers would recommend that the
President veto the bill, if it is presented to him in its current form.

Because of the bill's unworkably low standard of evidence and broad scope,
the bill would require the identification of scores of entities in member
countries of the multilateral regimes - entities that have complied with
their country's laws and the rules of the nonproliferation regimes. This
would have the effect of undermining multilateral support that is vital to
effectively fight proliferation, as well as support for other U.S. goals.

While improvements have been made to the original legislation, the bill's
reporting requirements remain onerous and unworkable and would divert
scarce resources away from the fight against proliferation. In addition,
the bill's sanctions are unnecessary given the wide range of existing
nonproliferation sanctions laws and the discretionary legal authorities
that the Administration has available and has already applied to penalize
ten Russian entities involved with Iran's missile and nuclear programs.

H.R. 1883 is particularly inappropriate now that the United States has
achieved substantial progress with the Russian government in establishing
the policy, legislative, and institutional basis for a system of effective
Russian export controls. The Russians have recently enacted tough new
export control legislation, and have adopted a U.S. game plan designed to
cut off future contacts between Russian entities and Iran's WMD/missile
programs. These controls are essential for Russia to be able to police its
own industries, scientists, and engineers and to stem the flow of Russian
technology and expertise to Iran. Passage of H.R. 1883 would ignore the
progress achieved and would undermine the efforts of Russian officials who
have cooperated to strengthen export controls.

The restriction on "extraordinary payments" in connection with the
International Space Station (ISS) could negatively impact ISS assembly and
operations without advancing U.S. nonproliferation goals. Despite
technical changes and exemptions, the determination standard for
"extraordinary payments" is far too broad, making compliance inherently
subjective and ill-defined. The restriction could hinder NASA's ability to
work with Russian organizations that are cooperating with the United States
to enforce nonproliferation measures, as well as strengthen elements in
Russia that oppose Russian participation in the U.S.-led ISS. It could be
viewed by other ISS partners as a unilateral U.S. action in a multilateral
program. Finally, it could result in significant cost growth and schedule
delay to the United States and other ISS partners by restricting needed
access to Russia?s unique capabilities and expertise, and constrain NASA's
ability to rapidly respond to emergent safety and operational requirements
on the ISS.